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Don’t Write a Big Check to the IRS That You Can’t Cover

Dec. 10, 2020, 9:45 AM

If most of my clients could write a big check to the IRS and make all of their tax problems disappear, they would do it.

That idea occurred to Richard Graham, too, with one major flaw: he didn’t have cash in the bank to cover it. And when his $3.6 million check turned out to be bogus, he was arrested and eventually convicted on two charges: passing a fictitious financial instrument, in violation of 18 U.S.C. 514(a)(2), and corruptly endeavoring to obstruct the administration of the Internal Revenue Code, in violation of Section 7212.

Graham appealed his ...